Select Committee on Environmental Audit Seventh Report

THE DRAFT CLIMATE CHANGE BILL

60. The Queen's Speech last November indicated the Government's intention to bring forward legislation on climate change; in March 2007, the Government published the resulting draft Climate Change Bill. Following public consultation and formal pre-legislative scrutiny from the Joint Committee on the Draft Climate Change Bill,[82] the Government has stated that it aims to introduce the Bill to Parliament in autumn this year.

61. Since the 2003 Energy White Paper, the Government has had a target to reduce UK CO₂ emissions by 60% by 2050, "with real progress by 2020". In the draft Climate Change Bill, the Government is proposing to enshrine this 2050 target in statute (at the level of "at least 60%"), and in addition firmly define what "real progress by 2020" is to mean by proposing an additional statutory target reduction of 26-32% by 2020. Additionally, the Bill proposes that the UK set itself rolling series of three consecutive five-year carbon budgets, representing a limit on the total quantity of carbon dioxide emissions over a specified period of time. This design would allow for a trajectory to be set towards the 2020 and 2050 targets, while still allowing year on year flexibility (for instance, to cope with variations in emissions from one year to the next depending on factors such as harsher winters). The Bill further proposes the creation of a new independent body, the Committee on Climate Change, to provide advice to the Government in respect of its emissions reduction policies. The Committee would produce an annual report on the UK's progress towards the targets and budgets, to be laid before Parliament. Every five years the Government would be required to lay before Parliament a compliance statement on whether that carbon budget has been met, with the Committee on Climate Change assessing its validity. Finally, the draft Bill contains enabling provisions to set up future domestic emissions trading schemes. Key provisions of the Bill are set out in slightly more detail in Figure 4.

62. Overlapping our inquiry have been both the formal pre-legislative scrutiny of the Joint Committee on the draft Climate Change Bill, and another inquiry specifically into the terms of the draft Bill which the Environment, Food and Rural Affairs Committee have decided to make as part of their regular programme of inquiries into the policies of Defra. The specific focus of our inquiry differs from theirs: in looking at the draft Bill we have concentrated on how well it provides an adequate response to the issues raised by the Climate Change Programme Review.

Figure 4 Key Provisions of the Draft Climate Change Bill

The 2050 target

63. The draft Bill contains provisions to place an obligation on the Government to achieve at least a 60% reduction, from 1990 levels, in the UK's net annual carbon emissions in 2050. In addition, the Bill provides for the Secretary of State by order (i.e., without the need for primary legislation) to amend this percentage; but specifies:

(4) That power may only be exercised if it appears to the Secretary of State that there have been significant developments-

  (a) in scientific knowledge about climate change, or

  (b) in international law or policy,

that make it appropriate to do so.

The two main issues on which we took evidence were the percentage level of this target, and the nature of this "trigger clause" concerning circumstances in which it might be amended.

64. The majority of evidence we considered suggested strongly that the 60% target is inadequate. This target level was based on a recommendation made by the Royal Commission on Environmental Pollution (RCEP) in 2000. The RCEP's overarching aim in making this recommendation was that global warming should be limited to a rise of no more than 2^oC; according to the science at the time this was adjudged to require stabilisation of the global atmospheric concentration of carbon dioxide at 550 parts per million (ppm) by mid-century, which the RCEP worked out as necessitating a 60% cut in UK emissions. In the intervening time, scientific understanding of the requisite stabilisation total has moved on. This is something the Government itself recognises:

in the mid-1990s the EU proposed that the aim should be to limit global temperature rise to no more than 2ºC to avoid dangerous climate change […] At that time, it was thought that this equated to atmospheric carbon dioxide levels below approximately 550 ppm. The more recent work of the IPCC suggests that a limit closer to 450 ppm or even lower, might be more appropriate to meet a 2°C stabilisation limit.[83]

The Tyndall Centre for Climate Change Research have argued that, according to its calculations, the 60% by 2050 target contained in the Bill implies an atmospheric concentration, not of 550ppm CO₂, but of over 600ppm CO₂, and possibly in excess of 750ppm CO₂. Drawing on research published in the proceedings of the 2005 Exeter Conference on Avoiding Dangerous Climate Change, Tyndall argued that such atmospheric concentrations are very likely to lead to a rise in global temperatures of over 2^oC; and give rise to a 50% chance of exceeding 4^oC.[84] Dr Kevin Anderson of the Tyndall Centre warned: "The scientific evidence is there that 60%, it is a nice idea and helps us to sleep a little bit at night, but it has very little to do with climate change, so we need to go well beyond the 60%."[85]

65. The Secretary of State for Environment, Food and Rural Affairs confirmed to us that the Government was still completely committed to limiting global warming to a rise of 2^oC. By stressing the dangers even of this level of warming, he emphasised the reasons why the UK and EU were committed to holding a rise in temperature at no more than 2^oC:

Just to put that in perspective, I was told—and I am going to try and find out if this is right—that with a two-degree average change it will not be uncommon to have 50^oC in Berlin by mid century, so associated with a two-degree change is something that is pretty unprecedented in northern Europe, and I think that is quite a sobering demonstration because 50^oC is beyond our experience.[86]

66. Friends of the Earth wrote to us to argue that, in view of the disconnection that appears now to exist between the 2^oC target and the 60% target cut in UK emissions, the Government's stated climate change objectives were incoherent. Their comment—typical of much of the evidence we received—was that: "Therefore the whole basis for including a target for a 60% cut by 2050 is—and has been accepted by the Government to be—out of date. We do not therefore believe this target should be included in the Bill."[87] The response to this line of argument by both the Secretary of State and the Office of Climate Change was threefold: the 2050 target could be increased in the future; it was politically straightforward, for the purposes of passing this Bill, to retain a target which had already been broadly accepted, for instance by business groups; and in any case it is less important to get this longer term target right at this moment than to make progress towards the new target for 2020. As the Secretary of State put it to us:

The starting point is not 60 per cent; it is at least 60 per cent, and those two words "at least", which are on the face of the Bill, are very important indeed […] I think it is right to build on the consensus around the fact that at least 60 per cent in terms of CO₂ is the right place to start. The first priority is to get our system of carbon budgeting up and running. That is the first task of the Carbon Committee, to get 15 years' worth of carbon budgets up to 2022, which is what business wants. Business wants that long term certainty about what they are going to be required to do up and running and then we can consider whether or not it is right to shift the figure up, but at the moment business decisions will be governed by the shorter term target of 2020.[88]

67. There was some understanding in the evidence we heard of the Government's position. Climate Change Capital commented, "the use of statutory domestic emission reduction targets represents new political territory and therefore establishing the Bill with these well-established targets in place is probably a pragmatic first step," while Professor Ekins thought that it might possibly "be easier to get the Bill into statute at the 60% level and then increase the target, if that seems to be even more justified by the science than it currently is. It may be that it will be easier to do it like that than to put an 80% target in from the beginning." Having said this we did not receive any evidence which argued strongly that the 2050 target should not be increased. (While BCSD-UK told us they were not pressing for the target in the draft Bill to be increased, they gave as their reason that 60% was the target endorsed by their parent body, the World Business Council for Sustainable Development, rather than arguing that a more ambitious target was to be opposed in principle.) [89]

68. The Tyndall Centre argued that the UK's 2050 target should be increased to around 90%, with a 70% cut by 2030. They arrived at these figures by working backwards from a target to stabilise global atmospheric carbon dioxide at 450ppm in 2050. Above all, they stressed that it was more important to focus on staying within the overall cumulative emissions budget rather than on meeting a target for a percentage reduction in annual emissions in 2050. In fact they have gone so far as to say: "It is an act either of negligence or irresponsibility for policymakers to continually refer to a 2050 target as the key driver in addressing climate change."[90] The logic of their argument is that we need to start making immediate and consistent year on year reductions in our annual emissions. According to Tyndall, this means: "Assuming emissions can actually be stabilised by 2010, the mean annual reduction in carbon intensity between 2010 and 2030 is in the region of 9%, with the decade between 2020 and 2030 requiring a drastic 13% reduction in carbon intensity year on year."[91] We would observe, however, that according to the research Tyndall are drawing on, even if the UK made this profound effort and even if it were matched by the rest of the world, the 450ppm CO₂ level it would stabilise at would still lead to around a 70% chance of exceeding a rise of 2^oC.[92]

69. The Government's policy towards the UK's 2050 target is clearly incoherent. The Government remains committed to limiting global warming to a rise of 2^oC; but it also acknowledges that, according to recent scientific research, a cut in UK emissions of 60% by 2050 is now very unlikely to be consistent with delivering this goal. It is true that where the Stern Review talks about the required distribution of emissions cuts between developed and developing countries, it does (just about) correspond to the Government's existing line on its 2050 target. Referring to research which analyses four different mooted ways of apportioning emissions cuts (including Contraction and Convergence), Stern concludes that "for all developed countries, action to meet a 450ppm CO2e goal would require quotas to be set in line with a reduction in emissions of 70-90% on 1990 levels by 2050, and for a 550ppm CO2e goal the reduction would be at least 60%."[93] But while the Office of Climate Change was justified in telling us that the "at least 60%" target in the draft Bill is within the range discussed in the Stern Review,[94] this is clearly the minimum in emissions reductions which the Stern Review sets out. In fact, Stern states that this would correspond to a 63%-99% chance of exceeding a warming of 2^oC, and describes this level of global warming as "a dangerous place to be, with substantial risks of very unpleasant outcomes".[95] We recommend that the 2050 be strengthened to reflect current scientific understanding of the emission cuts required for a strong probability at stabilising warming at 2^oC.

70. We recommend that the Government publishes the rationale for its 2020 and 2050 targets, preferably including the central formula upon which they are based, in the Climate Change Bill. This rationale should make clear the size of complementary caps on annual emissions required of other blocs of nations, the stabilisation target for global atmospheric concentrations of greenhouse gases, and the resulting projected temperature rises, which are implied by the Bill's targets for annual emissions from the UK, as well as the central assumptions used by the Government in making these correlations. The Bill should state that if the Secretary of State proposes to revise these targets, he must publish the rationale for the new target in like manner.

71. Above all, the Government must draw attention, at home and abroad, not just to percentage targets for the annual emissions in a certain year, but even more to the absolutely crucial issue of the cumulative total budget of greenhouse gases that the world can afford to emit by 2050 if it is to have a reasonable chance of holding global warming to 2^oC.

72. In terms of the way in which this cumulative global budget is divided up among individual nations, we recommend that the Government explicitly endorses, and promotes internationally, the Contraction and Convergence method, or a method similar to it. Under this method, emissions budgets allocated to each nation would be progressively amended until all would arrive at an equal per capita level, consistent with an internationally agreed stabilisation level. As we have previously noted, the Government has implicitly accepted this principle by endorsing the RCEP's recommendation for a 60% cut in UK CO₂ (which was based on C&C). We have also concluded that any framework which involves radical emissions reductions would in practice resemble Contraction and Convergence, given the current imbalance in per capita emissions between the developed and developing world, and the resultant necessity for the bulk of emissions cuts to come from developed nations in order to meet a global stabilisation target.[96] But this only underlines the inconsistency in the Government's framing of a target to reduce UK emissions without advocating an international agreement based on Contraction and Convergence, or something very similar.

73. The Tyndall Centre for Climate Change Research have made a very strong argument that the UK ought to make carbon reductions of 70% by 2030 and 90% by 2050. We recommend that the Government respond to Tyndall's recommendations; and if it is rejecting them, explain why.

74. While we note that the Government has included a "trigger clause" in the draft Bill for amending the 2050 target, it states that the Secretary of State "may only" revise the target if one or both of its specified qualifications are met. We are concerned that this may put fetters on the ability of future Governments to respond to the threat of climate change. It is perhaps possible that the wording of this clause may encourage or make it easier for opponents of a tougher target to mount a political or legal challenge, based around the test of whether there truly have been "significant developments", in the event that a Government decides to raise the target above 60%. We recommend that the power to amend the target be significantly less circumscribed.

The 2020 target

75. The draft Bill also contains a provision to put into law a target to reduce UK carbon emissions, from 1990 levels, by between 26% and 32% in 2020.[97] The Government's consultation document, published alongside the draft Bill, explains that

there is a risk that a commitment for 2050 alone is too long-term; it might not encourage the action needed over the next few years that will be key to achieving our longer term goals. This is why we also want to put into statute a duty to ensure the trajectory to 2050 is consistent with a reduction in CO2 emissions by 26-32% by 2020, consistent with the trajectory to 2050. We believe this is achievable at acceptable cost with the right policies and actions.[98]

There is a strong case for arguing that this 2020 target is more important than that for 2050; or at least, it is more valuable at this moment to set an interim target than to finalise the target for 2050. This was certainly the view, for instance, of Professor Ekins, who argued: "To be honest, from this perspective in 2007, whether [the 2050 target] is 60 or 80% is much less important than establishing a credible interim target which will start us reducing carbon emissions rather than increasing them from now. That seems to me to be the really key issue which we ought to be focusing on."[99]

76. The provisions in the draft Bill surrounding this 2020 target are similar to those for the 2050 target: this "may only" be done if there are significant developments in climate science or international law which make it appropriate. However, whereas the draft Bill refers to the level of the 2050 target as "at least 60%", it imposes a maximum limit on that for 2020: "at least 26%, but not more than 32%".[100]

77. Our first question is whether the 2020 target is set at a level sufficiently challenging to be consistent with, not just a 60% target for 2050, but a higher target—perhaps 80% or 90% —should the 2050 target be amended in this direction. The Office of Climate Change were satisfied that one was consistent with the other—at their current levels: "I think it is also important to say that [the 2020 target] it is part of the trajectory to 2050 so, in a sense, as long as the mitigation curve passes through that range on the way to the 60% target by 2050 then that delivers the outcome which the Bill is about."[101] But as for whether it would still be consistent with a higher target for 2050, the evidence we heard from RSPB was less certain: "We have had discussions with Government about what point you would need to be at 2020 still to be on a reasonable trajectory towards an 80 per cent reduction. It would have to be the very top of the range of things that they are proposing at the moment (between 26 and 32 per cent) and possibly slightly higher."[102] This conclusion was echoed by Professor Ekins, who argued: "The only difficulty with 80% is that in my view you would need to bring the interim targets up to make it a credible trajectory".[103] However, the Secretary of State told us: "fortunately the target that has been set for 2020 of 26-32% reduction is consistent with higher levels of reduction come 2050."[104]

78. The Government should set out in detail where the UK needs to be in terms of emissions reductions by 2020 in order to be on track to meet other possible, and more challenging targets, for 2050. Especially given that some have suggested that that the 26%-32% target for 2020 would have to be increased in order to meet a more stringent target for 2050, we recommend that the restrictions in the draft Bill on amending the 2020 target be taken out. We are also concerned that setting a target range in practice encourages people to aim for the bottom end of the range, as this requires the least effort while still achieving compliance. For this reason, we recommend that the 2020 target be amended to read "at least 32%", rather than "26-32%".

79. The Secretary of State was very confident when discussing the matter with us that: "We get to 26% reduction by 2020 if we implement all the policies that we have got at the moment, so that is the base on which we are building. Obviously we want to go further […]"[105] The Office of Climate Change were slightly more circumspect, telling us that the 26% figure relates to "the upper end of optimism".[106] The 2007 Energy White Paper clarifies: "If we take the upper end of the range of savings we have estimated, we would be on course to achieve emissions savings just within the range set out in the draft Climate Change Bill (i.e. achieving just over a 26% reduction on 1990 levels)."[107] The DTI's latest Updated Energy and Carbon Emissions Projections (May 2007), underlying the Energy White Paper and published at the same time, spell this out in more detail: including all the policies in the White Paper, and making assumptions as to the impact of the EU ETS beyond 2012, "emissions are projected to be 119.2-128.8 MtC in 2020; equating to a 20-26% reduction on 1990 levels."[108]

80. It is clear to us that the Government will have to introduce more radical policies into its Climate Change Programme very soon if it is to meet even the 2020 target as currently set. Current measures, including those introduced by the recent Energy White Paper, are only projected to get us nearly to the bottom end of 2020 target range - and this at what the Office of Climate Change described to us as "the upper end of optimism". The Government has thus far consistently overestimated the impact of its carbon reduction policies, while underestimating the upward trend in emissions from social and economic developments. The lesson of the UK's failure to meet its 2010 target is that the Government must aim to overachieve its target for 2020. We recommend therefore that the Government introduce other measures projected to achieve at least the top end of the 2020 target, a reduction of 32%.

International aviation and shipping

81. The draft Bill excludes emissions from the UK's share of international aviation and shipping from the UK 2050 and 2020 targets. This is consistent with the Kyoto Treaty, which excludes international aviation and shipping from any national targets, the reasoning being that there is not yet any international agreement on the method by which these emissions should be divided and attributed to individual states. However, under Kyoto, signatory nations are obliged to keep track of what, under one methodology, is worked out as their share of these emissions, and they are thus entered as memo items in their national emissions accounts. Figures from the UK's inventory show a rise in CO₂ from international flights from the UK over the period 1990-2005, from 15.7MtCO₂ to 35MtCO₂, an increase of 123%; for international shipping there has been a small decrease, from 6.7MtCO₂ to 5.9MtCO₂, a fall of 12%.[109]

82. The Government's position on the inclusion of these emissions, expressed to us by Defra and DTI, is that: "The UK is active in lobbying for support within the international community for including international aviation in a post-2012 regime under the Kyoto Protocol. Provision has been made, in the draft Climate Change Bill, for the Secretary of State to amend the baseline and target to include international aviation and shipping emissions should international agreement be reached."[110] Clause 15(3) of the draft Bill states:

If there is a change in international carbon reporting practice relating to aviation or shipping, the Secretary of State may make provision by regulations as to the circumstances in which, and the extent to which, carbon dioxide emissions from international aviation or shipping are to be regarded […] as emissions from sources in the United Kingdom.

The Explanatory Notes to the draft Bill underline that the power of the Government to include international aviation and shipping emissions within the UK's targets for 2020 and 2050 "may only be exercised in the event of a change in international carbon reporting practice relating to aviation or shipping."[111] Should this power be exercised, the provisions allow the Secretary of State to define how and when these international emissions would be included within the UK's carbon budget and targets.

83. We received some trenchant submissions which criticised this section of the draft Bill, and called on the Government to include international aviation and shipping emissions from the outset. The Aviation Environment Federation (AEF) criticised the basis of the Government's position by arguing that international negotiations on the attribution of emissions from international aviation remain deadlocked, with little sign of progress:

reaching an agreement is a distant prospect: both methodological and (we understand) highly sensitive political issues remain to be resolved, and while Europe continues to press for the resumption of talks at the UNFCCC's Subsidiary Body for Scientific and Technical Advice (SBSTA), certain states (notably Saudi Arabia), remain uncooperative. Without consensus, international progress in this forum is effectively blocked.[112]

For this reason, AEF concluded: "the reasons that [the Government] have given for excluding aviation do not really stack up". Friends of the Earth (FoE), among others, argued that, while the ultimate goal should be to arrive at an international agreement on allocating these emissions, there was no reason not to go ahead and include international aviation and shipping within the targets in the Bill, even if this were only a "stop gap" until such international agreement is achieved.[113] FoE and others argued that international emissions could be included in the Bill on the same basis that they are currently recorded as memo items to the UK's Kyoto accounts. AEF commented that this methodology has already been "agreed by the Intergovernmental Panel for Climate change, so there is a measure of international consensus. And anyway it is a domestic target so why do we need international consensus?"[114]

84. The reason why these submissions were calling for international aviation and shipping to be included from the outset was nicely expressed by Friends of the Earth: "a "carbon management system" that simply leaves these emissions out is a rather like a calorie-controlled diet that opts to exclude calories from chocolate."[115] The longer the delay in bringing these emissions within the UK's statutory declining carbon budget, the bigger the shock to that carbon budget when they are finally added. A sudden addition of extra sources of carbon could make it harder for the UK to meet its next carbon budget, especially given that emissions from aviation would have been following an upward trajectory while the rest of the economy would have already been feeling the pressure to move onto a downward trajectory. In effect, this might necessitate even greater cuts, above those already allowed for, by other sectors of the economy, with all the difficulties this might entail.

85. An alternative concern was that, to avoid these difficulties, the terms under which international aviation and shipping are added would be relaxed—which would mean inflating the UK's overall carbon budget, and undermining the purpose of the Bill. As the AEF explained:

the Bill […] recognises the fact that aviation emissions have been growing very fast and that if they were to be included from their 1990 levels at some point down the line you would have quite a shock to the targets and they would have to be adjusted in some way, so it makes provision to include them at whatsoever level and in whatsoever manner and with reference to whatsoever baseline the Secretary of State sees fit. So we would then have a dilution of the targets. If 60% is pointing to a given stabilisation target, for example, and aviation emissions are then added into it further down the line at a much higher level, it makes a nonsense of that stabilisation target.[116]

86. We put these points to the Secretary of State and the Office of Climate Change. The main argument of the OCC was to stress the risks of "perverse effects" of including international sources of emissions over which the UK did not necessarily have the power, unilaterally, to curb:

For example, in shipping, do we end up with ships being registered elsewhere rather than being registered in the UK? [… There is] an argument about whether we have policy levers to immediately take on UK legal responsibility for emissions where we do not control all the levers to reduce emissions. Shipping is the best example where if we took on 50% of emissions for all shipping which passes throughout UK waters, for example, we have precious few ways to act on those outside international agreement; and, therefore, we took the view that it would be much more sensible to allow the Climate Change Bill to evolve and add emissions later, than to artificially take on responsibility for them in advance of any international agreement.[117]

87. On this argument we countered that:

You are saying, "We don't have the policy instruments to deal with this, so pretend it doesn't exist". It seems a rather backwards way of thinking. Is not the point about policy effectiveness separate from the point about whether these emissions are there in the first place; and we should be trying to do something about them, and trying to think of some more effective way rather than waiting until an international agreement occurs? Your point about the transfer registration, that might work in some cases but not all, so there would be some effect but you would not have the 100% effect you might have if you controlled the whole thing?[118]

We would further observe that the OCC's arguments only referred to shipping, but not aviation, where the issue of a transfer of registration to another country should not apply.

88. We also put to the OCC an argument that was made by EEF: "Government should produce two sets of forecasts—one covering 'domestic' emissions alone and one providing a more complete picture of emissions (i.e. including contributions from international aviation and shipping). […] Tracking all major sources of emissions would provide a more complete picture of the UK's contribution to climate change".[119] OCC responded, first, by referring to the publication of historic emissions from these sectors as a memo item to the UK's Kyoto accounts. Second, they drew our attention to CCP 2006: "there is information in there on projections also of the growth in greenhouse gas emissions from aviation and shipping. The Government publishes that information."[120] On this latter point we would observe that this is not quite what we were talking about. We can find a reference in CCP 2006 to projections of CO₂ from aviation,[121] and another to projections of methane and nitrous oxide from aviation and shipping.[122] However, the CO₂ projections for aviation are from a White Paper published in 2003,[123] have not been updated since, and are not integrated into the DTI's main emissions forecasting programme; nor are there any projections for CO₂ from international shipping.

89. The Secretary of State dwelt on the forthcoming inclusion of aviation within the EU Emissions Trading Scheme, scheduled to commence from 2011. His first argument was that it was sensible to wait until the methodology for attributing international aviation within the EU ETS was finally agreed before doing so in respect of the UK's domestic targets: "Since we have got EU agreement to get this in, since we are going to have 27 nations figuring out the basis of allocation methodology, I think it is not unreasonable for me to say let us do it on a basis that everyone else uses and then it will be in and we will be working on a common basis."[124] In more detail, he clarified:

In respect of aviation, there are two things that are under discussion at the moment that we want to get sorted out before including them. One is the actual measurement and how you include the fact that you are emitting at 35,000 feet, how much more damage does that do, so a calculation of the amount of damage. Secondly, there is the allocation issue. If you are flying from A to B do you allocate to where you are going to or where you have come from, or do you do half and half? We want to get those things sorted out.[125]

90. The first point is essentially asking whether, in including aviation within a carbon budget, one should multiply the size of its emissions of CO₂ by an "uplift factor" to take into account the extra contributions of flying to global warming—for instance, from contrails formed at high altitude. It is commonly expressed that aviation's overall global warming impact is between two and four times that of its simple carbon dioxide emissions. On this point we heard some contradictory arguments, relating to a recent scientific paper by Forster et al which questioned the practice of multiplying CO₂ emissions by an uplift factor.[126] The main argument of Forster et al is that because CO₂ emissions remain in the atmosphere for around a century and thus have a long term impact on global warming, while contrails and emissions of other gases make a more intense but shorter lived impact, it is very difficult to express the sum of these contributions as a simple multiple of the CO₂. AEF's comment on this argument was to agree; but to argue that it does not really matter, since however one seeks to calculate it, aviation's contribution to global warming is significantly greater than that of its CO₂ emissions alone.[127] The Tyndall Centre were slightly more cautious:

The problem with these multipliers is that you are trying to compare things that are not like for like, comparing a contrail that lasts for some few minutes over one part of France with global CO₂ emissions is not something that we think you could ever mathematically put together and come up with an answer that is going to help policy. The problem is that when you put in a multiplier your policy implication might be to fly lower to get rid of the contrail, because that seems to have more of an impact, but then you are increasing the CO₂ and then you have a problem that is with you for another 100 years.[128]

91. Bringing this back to the Secretary of State's specific point, we would merely observe that under current proposals the EU ETS will count CO₂ alone rather than using a multiplier to calculate aviation's emissions under the Scheme; and that this is also the basis of current reporting of international aviation emissions under Kyoto. In other words, these already tally; and thus this raises a question over whether waiting for the inclusion of aviation in the EU ETS is a proper cause for delay in including international emissions in UK targets, on the basis on which they are already recorded as memo items in the UK's Kyoto accounts.

92. As for the Secretary of State's second point, the question of how international emissions will be allocated to individual countries, AEF argued that the Government is unlikely simply to adopt the attribution methodology that will be agreed for the EU ETS, as this looks set to count the emissions of both incoming and outgoing flights. If applied to the UK, it would mean the Government accepting a greater share of global emissions from aviation than it currently records in its Kyoto accounts (where it counts the emissions from all international departures from UK airports, but not arrivals). A further problem will occur if, as is possible, the European Commission sets caps on aviation by airline rather than under each Member State's National Allocation Plan; how would this inform the way in which the UK includes its share of international aviation emissions within its domestic targets?

93. Another argument made by Mr Miliband against the need to bring international aviation immediately within the UK's carbon reduction regime was that, once aviation is included within it, the EU ETS will place a cap on aviation emissions, so that "if, for the sake of argument, aviation grows as fast as or faster than you suggest or technological progress in aviation is slower than you or I expect, the price of carbon will rise within the ETS, thereby increasing the incentive for aviation operators and anyone else to take tougher action against emissions. […] If aviation goes the wrong way in terms of emissions then the price mechanism kicks in in a serious way."[129] On this point, we would re-emphasise the conclusion from our recent report on the EU ETS, that the effectiveness of including aviation in the Scheme depends on the stringency of the cap. Under proposals for the initial inclusion of aviation, the cap—and hence the impact on airfares, and thus demand for flights —is expected to be relatively weak. WWF, for instance, point to reports which suggest that under current proposals the Scheme would, by 2020, raise ticket prices by only €4.6 (£3.10) for a return short haul flight, ranging to only €39 (£26.25) for a long haul return. Given the uncertainty that still remains as to the stringency and effectiveness of future caps, we would argue that this is another argument for taking action now to curb emissions from this sector, and to include them voluntarily within a UK carbon reduction regime.[130]

94. Finally, the Secretary of State argued that even if aviation emissions were projected to carry on rising:

it does not seem to be unreasonable for us as a country to make a social, economic and technological choice that aviation should be a rising share of our total allowable emissions as long as we live within our emissions envelope. What it requires though, if aviation is going to become a rising share of the emissions that we are allowed, is that we take more radical action in other sectors—electricity, heat and transport. [… I]t seems to me there are technological, social and economic reasons why people might want to choose to fly more. If they do we are going to have much less pollution from other sectors, which is far from impossible.[131]

We would respond to this by drawing attention to the argument that we and our predecessor Committee have made repeatedly: it is going to be difficult enough for different sectors of the economy to meet a 60%—or greater—reduction target, without having to make disproportionately greater cuts to accommodate the rise of aviation.[132] Not only will this be difficult, but according to some scenarios of aviation growth it will be literally impossible. As we highlighted in a recent report, if one combines "High Aviation Growth" figures in research commissioned by Defra with an 80% cut in emissions target, aviation considerably exceeds the 2050 carbon budget for the entire country.[133]

95. A further point we discussed with the Secretary of State was the restriction in the draft Bill on including these emissions "only […] in the event of a change in international carbon reporting practice relating to aviation or shipping."[134] As we asked him: "Does that mean that the rest of the world has a veto on what power you as Secretary of State would have to take unilateral action if you thought that was the right thing to do?" Mr Miliband was adamant that "No, no one else has vetoes."[135] We still have concerns, however, that while no other state would of course have the power under UK legislation to prevent the Government acting unilaterally, this clause might still provide a basis for a legal challenge within this country.

96. Overall, we are unimpressed by the Government's arguments for excluding international aviation and shipping emissions from the UK's carbon reduction regime. While the draft Bill contains provisions that allow these emissions to be included in the future, we recommend that they be included immediately. Despite the arguments of the Secretary of State, we do not believe the Government needs to wait until the terms under which aviation will enter the EU ETS are fully confirmed before doing this. There already is an internationally agreed methodology for attributing and recording these emissions as memo items to national Kyoto accounts; the Government should simply use this to track these emissions within the UK's carbon budgets. This, in turn, means the Government should only count the simple weight of CO₂ from international aviation within these carbon budgets, rather than multiplying it by a factor of 2 or more to reflect the wider global warming impacts of flying. These extra impacts should not be ignored, however, but merit additional policy responses.

97. If the inclusion of international aviation and shipping has to be delayed, the Bill should be more prescriptive about and when they are to be included. The flexibility currently there in the draft Bill threatens to undermine the UK's overall emissions targets. The draft Bill's qualification that a future Secretary of State "may only" include these emissions if there has been an international agreement on them seems potentially to tie the hands of future Governments for no good purpose, and should be removed.

98. Finally, if these sectors are not included from the outset, then the Government published figures for the UK's annual emissions and forecasts of future emissions should clearly indicate what the level of these emissions—and progress towards meeting national carbon budgets and targets—would be, once international aviation and shipping were included. This would aid transparency, and focus attention on the effects that an ongoing upward trajectory in aviation emissions has on progress towards the UK's short, medium and long term targets. In order to do this, projections of future emissions from aviation and shipping must be improved, frequently updated, and fully integrated into the Government's Updated Emissions Projections papers.

Use of emissions trading

99. The draft Bill would allow for the UK's statutory carbon targets to be partly met through emissions trading—that is, by the UK's funding quantified emissions reductions in other countries, and receiving certified carbon credits in return, to be set against the UK's domestic targets. The draft Bill sets out:

• a duty on Government to produce regulations setting out the types of overseas credits that can count towards the UK's targets, and the amount of carbon dioxide emissions reductions that each type of credit represents;
• a requirement for the Government to report on the number and type of carbon credits used against UK targets;
• powers for the Government to set up an organisation and provide it with funds to purchase overseas credits, if necessary to help the UK meet its targets; and
• a duty on the proposed Committee on Climate Change to advise the Government on the optimal balance between domestic and overseas effort to inform the Government's decision-making.

100. We have previously expressed a number of reservations about the use of emissions trading to help meet domestic carbon reduction targets, while acknowledging the potential benefits of emissions trading (in helping to reduce the costs of mitigation, and in securing flows of finance to fund low carbon development in the developing world) and the potential significance of the EU Emissions Trading Scheme. Our concerns have been, first, the extent to which carbon credits are funding real reductions in global emissions; second, the extent to which the purchase of carbon credits obscures the transparency of public reporting as to each nation's domestic progress in reducing emissions; and third, the practical feasibility of relying, in order to meet targets for 2050, on finding significant volumes of surplus carbon credits to buy from other countries, when all nations will surely find it very challenging to meet their domestic emissions targets for 2050 under any post-2012 regime.

101. Several submissions directed similar criticism towards the role of emissions trading within the draft Bill. WWF argued that if the UK made significant use of carbon credits to meet even its shorter term targets, the pressure within the UK to abate emissions would be reduced, with the result that we would continue to build and invest in high-carbon infrastructure, thus locking us into a high-carbon pathway for decades to come (or necessitating the costly scrapping of much infrastructure).[136] This was an argument developed by Professor Ekins, who stressed that

the offsetting mechanism needs to be very, very sparingly employed in developed countries' targets and the great majority of them should be through domestic action, so that a rich economy like ours can show that it is possible to maintain civilised life and have low carbon emissions which, at the moment, is the hypothesis that needs to be proved. […] What we know we have to find is the way of living civilised lives with low carbon emissions and that should be the objective that is pursued by the Bill.[137]

The Energy Saving Trust argued that there was no reason not to deliver savings from within the UK, and indeed still plenty of room for finding cuts through simple energy efficiency; thus they "would like to see the majority, if not all, of the emission reductions coming from the UK". Overall, EST argued that the proportion of carbon credits used against UK targets should be capped, perhaps to 5% or 10%, and that much only allowed for sectors in which industrial competitiveness is a concern.[138]

102. Several submissions also discussed the fundamental problems with the robustness of emissions trading. Friends of the Earth stressed the difficulties in assessing whether carbon credits, nominally each equivalent to a tonne of carbon, can really be judged to equal and thus cancel out an equivalent tonnage in actual emissions from the UK: "This depends on a multiplicity of factors - such as assessment of whether that tonne would have been (at least partially) saved anyway, whether it [is] measured as a reduction on current emissions, or from a projection of future demand. It is a problem that bedevils carbon offsetting schemes as well as trading schemes." Such difficulties led FoE to the conclusion, typical of the arguments we heard from other environmental NGOs:

We are therefore concerned that the Bill should not allow the total freedom to trade carbon credits to meet carbon budgets until the frameworks that such trading takes place within are sufficiently robust to be moving us on the correct trajectory to the carbon cuts we need to see. Until that time we believe serious consideration should be given to restricting the use of trading as a mechanism to meet the budgets, perhaps by

• Setting a strict limit for the amount of effort to be made to meet budgets domestically, and the amount that can be "bought in".
• Operating a kind of "exchange rate" where independent assessment judges a tonne of carbon saved domestically to be equivalent to, say, just half a tonne under a trading scheme. In such cases, credits for two tonnes would be needed to have the same effect on the budget.
• Restricting trading to only robust schemes.[139]

To the extent that carbon credits are used against UK targets, EST were one of several organisations to argue that there should be "a system of parallel reporting of parallel targets which showed you the reductions achieved just within the UK so that we can clearly distinguish that which is purchased overseas from that which is meeting our own targets from our own efforts".[140]

103. At the same time, RSPB discussed the negative effects that might be caused by very tight restrictions on emissions trading, essentially that this could reduce the flow of funding to build low carbon infrastructure in the developing world. For both RSPB and WWF one solution to this was to ensure that the reduction targets adopted by the developed nations such as the UK were very demanding. As Keith Allott of WWF put it: "The more ambitious the targets the government is prepared to put on the face of the Bill then to an extent the more relaxed we are about using some trading to count towards those targets. Having a weak target (with essentially unrestricted trading) is the worst of both worlds."[141] They also made the argument that low carbon investment in the developing world could be funded from auctioning allowances to emit carbon within cap and trade schemes (such as the EU ETS).[142]

104. Climate Change Capital were much more positive about the use of emissions trading, making a strong argument as to the increasing robustness of current trading schemes such as the Clean Development Mechanism, and stressing the importance of emissions trading in providing the finance for low carbon and sustainable development projects in the developing world. Interestingly, they came up with something of a counter-argument to the point made by WWF, that if the developed world relies too much on buying carbon credits it will become locked into high carbon infrastructure:

if you take the example, for instance, of the massive rural-urban migration occurring in India and China, which is unprecedented in history and will never occur again, we have one chance to build cleaner infrastructure, to support clean urban planning, to encourage mass transits instead of building of roads, to build clean buildings, close to zero carbon buildings. We have one chance at that because we all know that retrofit is more expensive. If money is sent through well-designed mechanisms towards that kind of effort, I do not really mind whether that slows down retrofit here, because that is a one-chance opportunity that the whole world should be contributing to. Of course, we will have our own objectives and that will be part of the deal; the key thing is the quality of the investments you are doing overseas.[143]

105. We expressed some of the concerns made about emissions trading in the context of the draft Bill in our recent evidence session with the Secretary of State. In response he stressed the limits to be placed on the use of carbon credits under the principle of supplementarity - which he defined as rules "designed to ensure that your purchases abroad are to supplement your domestic effort, not to be instead of it" - and which underpin the restrictions in the draft Bill. [144] To this we would observe that there is still much to be done to define and prove the robustness of these limits. As, for instance, the Defra's own consultation document on the draft Bill explains:

5.31 There is a lack of clarity over what precisely the supplementarity principle means in terms of a quantitative limit on emissions reduction effort which can be achieved overseas. For one thing, no quantitative limit is explicitly given in the guidance. For another, the principle refers only to Kyoto project mechanisms (CDM and JI) for complying with Kyoto obligations, whereas it is also the case that EU ETS allowances purchased overseas are strictly speaking international rather than domestic effort. […T]here is no limit on the degree to which organisations within the EU ETS system can reduce their emissions through purchasing allowances, many or all of which could come from other EU Member States.[145]

106. We have concerns as to the scope in the draft Bill for the UK's carbon reduction targets to be partly met by purchasing carbon credits from other countries. The Government must ensure that carbon credits are not used to forestall the early transition in the UK to low carbon infrastructure in power generation, buildings and transport, as this could mean that the country is locked into carbon-intensive lifestyles for decades to come. At the same time, we certainly recognise the potential importance of trading in providing funds for low carbon infrastructure in the developing world. We would simply argue that this must not become an "either/or": the Government should ensure that the UK's targets are sufficiently challenging that they drive decisive emissions reductions at home and abroad.

107. Where emissions trading is used to meet UK targets, it is essential that the Government distinguishes clearly between emissions reductions achieved within the UK and emissions reductions funded by the UK but taking place abroad. Thus far, in reporting the relationship of the EU ETS to UK emissions, the Government has been less than transparent. The problem with this is that it might foster a false sense of complacency about the progress and policies required to decarbonise the UK. The Government ought to adopt a code of practice for reporting UK emissions, and the Committee on Climate Change should audit Government press and statistical releases.

108. Above all, the Government should address the question: if all countries will have to meet challenging emissions targets by mid-century, how many are going to beat their targets and thus be able to offer surplus carbon credits to the rest? The Government has pointed to the research in the Stern Review which concludes that in order to meet a global 450-550ppm CO₂e target, all developed nations would have to make emissions cuts of at least 60%-90%, with many developing world countries allowed only a modest increase or a small decrease; but Stern clearly says that these figures "do not incorporate international emissions trading".[146] The Government should clarify what these targets would be once emissions trading is taken into account, under a range of scenarios. In doing this, the Government should be explicit about the maximum range of the UK's carbon budget to 2050 which could be made up by buying emissions credits from abroad, and still be consistent with Stern's global stabilisation targets.

Carbon budgets and reporting

109. The draft Bill sets out provisions for the Government to set statutory five-year carbon budgets, prescribing the maximum amount of carbon to be emitted from the UK in that period (while allowing for carbon credits purchased from abroad to be counted against this budget). The consultation document on the draft Bill explains how these would fit with the statutory targets for 2020 and 2050:

Of course, five years provides insufficient certainty for many businesses making longer term investment decisions. For this reason we are proposing to set a target for 2050 into statute, and provide additional short and medium term clarity by proposing that the trajectory to our 2020 target should be represented by setting in place three five-year carbon budgets, for the periods 2008-12, 2013-17, and 2018-22. This would provide a full fifteen year horizon of expected CO2 emissions reductions, and a strong, clear signal about the subsequent direction. Future carbon budgets would then be set to ensure that there were always three budget periods' worth of carbon budgets in statute, giving medium-term clarity whilst recognising that it is not realistic to guess conditions more than fifteen years in advance.[147]

The Bill also allows for carbon budgets to be revised, in similar though not as prescriptive terms as the provisions for amending the 2050 and 2020 targets.

110. In addition, the draft Bill sets out a number of provisions aimed at aiding Parliamentary and public scrutiny of the Government's policy framework for reducing emissions, as well as progress made by the UK in actually doing so. The Government has recently given itself a legal requirement to report to Parliament an annual assessment of its progress on greenhouse gas emissions reductions, under Section 2 of the Climate Change and Sustainable Energy Act 2006.[148] The draft Bill proposes to build on this, by requiring the Committee on Climate Change to report annually to Parliament, setting out its views on the UK's progress towards meeting its five-year carbon budgets, and the targets to 2020 and 2050; the Government would be obliged to respond publicly to these reports. Beyond this, the draft Bill also proposes that after setting the carbon budget for the next budgetary period, the Secretary of State would report to Parliament on how it—and the following two carbon budgets—would be delivered, giving details of the policies which would be implemented. After each budgetary period, meanwhile, another provision would oblige the Government to report to Parliament on whether and how the budget was met.

111. One major issue arising from these proposals is whether the five year carbon budgets are too long to prove effective in applying a consistent pressure to reduce emissions, or in holding the Government to account for meeting them. Friends of the Earth, which has spearheaded a long running campaign for the introduction of statutory annual reductions in emissions, expressed their concern that:

The Bill must therefore ensure that every Government is held to account, and cannot pass the buck to a future Government—or blame a previous one. There is a very real danger that as drafted—with five year budget periods that will almost inevitably overlap with two Parliaments—the Bill will fail to do this. […] It is far from impossible to imagine a situation where a Government approaching an election might duck some tricky decisions, or opt for tax cuts rather than investment in necessary low-carbon infrastructure or technology. […] After all, in such cases the blame for missing the budget would actually [be] taken by the successor Government. But the successor Government may feel it can get away with using the flexibility in the Bill to amend the budget, while blaming the previous Government who did too little to get on track for the budget that every[one] wanted to see met. Everyone blames each other—but crucially our carbon emissions are not cut as required.[149]

On this point David Middleton from BCSD-UK told us: "We are concerned about issues of responsibility amongst ministers. If it is a five-year reporting period, is there any retrospective responsibility on acts which have happened during the period of a minister when that minister may no longer be in post?"[150] The other main concern we heard about five year budgets was that it could foster complacency in the first two or three years; as EST expressed it: "We should not have that kind of luxury of being at the start of a 5-year period and what we do now perhaps does not matter too much as we will catch up later on."[151] The answer favoured by EST, as well as the environmental NGOs, was that there should still be annual targets within strict three or five year carbon budgets. This would provide the flexibility to exceed a certain year's targets due to unforeseen circumstances, while still providing the continual attention to, and accountability for, delivery.

112. Another significant issue concerns the provisions in the draft Bill to allow the Government to "bank" or "borrow" emissions between one five-year carbon budget and another:

• "Banking" would mean that if the UK were going to finish one five-year carbon budget "under budget"—that is, emitting even less than it was entitled to—the Government could choose to "carry over" the excess emissions entitlements into the next carbon budget, in effect inflating the next five-year carbon budget and making it easier to achieve.
• "Borrowing" would mean that if the UK were having difficulties in making its carbon budget for one five-year period, the Government could "borrow" a proportion (limited to no more than 1%) of the budget for the next five-year period; in turn, this would decrease the next carbon budget by the same amount, thereby making it harder to achieve.

The draft Bill requires the Secretary of State to obtain the advice of the Committee on Climate Change, and take this advice into account, before banking or borrowing, but does not require the Secretary of State to obtain Parliamentary approval. The advantages of the ability to bank and borrow are put forward in the Partial Regulatory Impact Assessment which accompanies the draft Bill: banking would help to incentivise the UK to make even steeper cuts in the short term, while borrowing would help the Government to cope with unforeseen circumstances in the final year of a five-year carbon budget.[152]

113. These provisions, and the rationale put forward for them, were largely endorsed by our witnesses. Tony White of Climate Change Capital stressed the reassurance that this provision of flexibility would give to investors—since: "Markets are concerned about things happening that are not expected, governments panicking and then you just do not know what is going to happen."[153] Paul Ekins, meanwhile, argued that banking, in particular, was very important:

It is absolutely critical that banking at least is allowed. Banking and borrowing are rather different in this field. Banking is critically important in order to give confidence in the carbon market, so that people will reduce emissions now, they will take early action, they will go for it right up to the limit of economic feasibility or economic viability, in the knowledge that if they save more carbon than they think they are going to, they will be able to offset those emissions against these very tough targets that are coming in the future. That is a very, very important incentive.[154]

Borrowing was more problematic, he believed, and needed to be kept within very tight limits, since "the natural instinct of practically everybody is going to say "Let's not do it today, let's do it tomorrow and then we can borrow against the future". Of course, if too many people borrow against the future, the future becomes unachievable."[155] The Bill does propose limiting borrowing to 1% of the budget, but Professor Ekins maintained: "That should be an absolute maximum because one per cent of quite a large number is quite a large number."[156]

114. A final issue which we looked at in relation to carbon budgeting is the steepness of the emissions pathways which ought to be set through them. EEF welcomed the 15 year horizon proposed for these carbon budgets, believing this would enable industry to build in requirements to adjust into their regular investment plans; however, EEF also argued that any requirement for steeper emissions cuts ought to be delayed, as the development and deployment of new technology would require long lead times. EST and others, meanwhile, argued strongly against this and in favour of "front-loading" emissions cuts. Their rationale for this was that, because carbon dioxide remains in the atmosphere for around century, the focus should not simply be on targets for reductions to be made in a certain year, but on constraining the cumulative total of emissions—and thus: "The earlier you prevent carbon emissions going into the atmosphere, the less the impact is on climate change."[157]

115. In the consultation document on the draft Climate Change Bill, the Government does explicitly discuss this as a reason for seeking to introduce its successive five year carbon budgets.[158] However, a number of submissions argued that it was not going far enough. EST, for instance, argued that the 15 year horizon of carbon budgeting proposed by the Bill was too short, and that it ought to be extended to 2050, in order to ensure there was a continual focus on short, medium, and long term efforts required.[159] The implication of their argument was that, by only setting budgets 15 years ahead, the Government might agree to initial carbon budgets that were set at too high a level, through not being made to focus on plotting an optimal path, with balanced demands on the UK in every carbon budgetary period, all the way to 2050. These comments were seconded by Nick Mabey, who argued that if the Government merely focused on meeting a carbon budget over a 15 year horizon it would be pursuing the wrong policies, as long term reductions were dependent on replacing high carbon infrastructure in power generation, buildings, and transport.[160]

116. Dr John Rhys and Mike Parker of the British Institute of Energy Economists (BIEE) Climate Change Group made a related argument, stressing that the Government should be more prescriptive in setting out the extent and timing of cuts required from different sectors of the economy. This, they argued, was necessary in order to provide realistic guidance as to what needs to be done to meet the UK's longer term targets. For instance, the BIEE Group observed:

Given the long lead-times involved in removing sources of inertia, introducing low carbon technologies and making the associated changes to infrastructure and institutions, the successful implementation of any 60-80% path is on a very tight schedule. To provide clarity and credibility there is a need to draw up time critical pathways for three particularly significant sectors—electricity, transport, and buildings. These account for about 85% of CO2 in the UK. A UK reduction of 80 % by 2050 is not feasible unless all three achieve close to 80%, or at least two achieve close to 100% while the third still achieves around 50%.[161]

117. We welcome the Government's proposals to introduce a national carbon budgeting system. Setting successive five year carbon budgets will help to span the gap between annual emissions figures and the target for 2020. We hope that these carbon budgets will ensure that there is constant political pressure to meet them every five years. They should also help define the pathway of emissions reductions through time that the UK will need to follow in order to meet its medium and longer term targets. In addition, the introduction of rigorous annual reports to Parliament on trends in emissions and on the impacts of carbon reduction policies, as well as reports setting out the suite of policies and their projected impact for each budgetary period, will show whether the UK is managing to follow its required emissions pathway, and should lead to a timely revision of policies if progress is slipping off track.

118. It makes sense for each carbon budget to run for longer than one year, to allow for unforeseen variations in emissions from year to year. But the Government should still set out an indicative target for UK emissions in each year, so as to apply continual pressure to reduce emissions. We also recommend that the successive series of carbon budgets should extend out all the way to 2050, so that all carbon budgets are consistent with the UK's overarching emissions objective.

119. Earlier budgets should contain steeper reductions: as the Stern Review made clear, early cuts in emissions are disproportionately beneficial. The Government should also examine the feasibility of introducing sector-specific emissions pathways to be defined to 2050, notably for power generation, buildings, and transport; this would help to identify in more detail the scale, timing, and nature of the developments needed in order for the UK as a whole to meet its targets. The desirability of such sectoral plans is illustrated by the lack of progress so far in reducing carbon emissions from transport, and the complacency about this shown by the Department for Transport. Writing to us last year, that Department assured us of their commitment by arguing that, according to DTI projections, by 2050 emissions from transport will be at the same levels as they were in 1990.[162]

120. One further aspect of the provisions in the draft Bill which we welcome is the proposed introduction of five-yearly reports on the impacts of climate change in the UK and policies for adaptation. RSPB have taken a lead in scrutinising this, and discussing its potential:

We have had conversations with the [Office of Climate Change] and others about this. Their interpretation of this is somewhat stronger than ours was initially. They take the view that the requirement is not just a reporting requirement but a requirement to bring forward a programme of action. That is certainly what we would like. We will be looking to strengthen the language so that other people cannot interpret it in the way we did which was just as a reporting requirement. We have a particular perspective on this as the RSPB because we are facing a situation where wildlife is already under substantial threats from all kinds of other pressures and is now faced with an additional, potentially knock-out blow as a result of climate change. We have what we believe is a totally reasonable expectation that, since these are human impacts, we find the resources and put forward the policies to allow wildlife to adapt. We take the view that that is important in the UK, but we also are talking to colleagues within the Stop Climate Chaos Coalition who work in the development movement and who have passionate concerns about funding for adaptation internationally as well as funding for the UK. We would like to explore the possibility of including an obligation for the government to report on the efforts it is making in terms of global equity to address the impacts of our emissions on the world's poorest people.[163]

We recommend that this requirement is accompanied by a Government programme of action on adaptation in the UK. The Government should incorporate into such a formal programme of action an international development strategy which identifies and works to address the impact of climate change on the world's poorest and most vulnerable communities. Following our recent suite of reports on the Government's approach to trade, development, and the environment, we may look more closely at the adaptation proposal in this draft Bill—and any wider initiatives it develops—in the future.

Committee on Climate Change

121. The draft Bill would provide for the creation of a new Non-Departmental Public Body (NDPB), to be called the Committee on Climate Change (the Committee). The Government's Consultation Document describes the purpose of this new body, at its briefest, as being "to independently assess how the UK can optimally achieve its emissions reductions goals". Further details are set out in Figure 5.

Figure 5 Outline of roles and duties for the Committee on Climate Change

122. A variety of different organisations broadly gave the proposal for the Committee a welcome; in particular, there was support for its being an independent body. There were two ways in which this was perceived as being a good thing. The first was so that it could provide oversight of the information published and analysis performed by the Government, the need for which had been highlighted by the failings of the Climate Change Programme Review. The Sustainable Development Commission had told us last year that they would welcome more independence in the production or at least auditing of Government emissions forecasts. As Sir Jonathon Porritt put it:

We have had discussions with ministers in Defra about this matter, and we have indicated that we regard it as hugely important. I genuinely cannot see any downside to it for government. If there is to be embarrassment on these issues it is better that they surface via a transparent process that others can point to rather than by something that is suddenly released at the dead of night by a government body that may well feel constrained by putting that data into the public domain. This is critical. We do not necessarily know that we are on track to achieving some of these targets.[164]

123. The Committee's independent status was also seen to enhance its ability to advise the Government on the level of carbon reductions required and the policies necessary to achieve them. Climate Change Capital were among many who hoped that the Committee would be able to help Government match its political response to the recommendations provided by the science, by depoliticising the debate over the introduction of potentially radical or unpopular measures:

The key issue is really de-politicisation. […] The Climate Change Committee, by de-politicising the process, by giving ministers the political space to say on an independent evaluation of the scientific evidence and the economic issues we think is the best way forward. Until now that has not existed. If you think about the impact that the Stern report has had, we are talking about a series of mini-Sterns, focused on the UK's policymaking specifically, which will give those decision makers some political space. [165]

CCC also stressed the importance of the Committee as an example which other governments might follow: "[E]verybody is watching this experiment […] If this works, people will sign up to it in some countries, not all, but there is a real chance that within the EU in particular the traded sector will be carved out of national policy making and put in a place that, over long periods, people can rely on."[166]

124. In relation to this discussion as to the advantages which the Committee's independent role could bring, we heard much debate about the parallels between the Committee on Climate Change and the Bank of England's Monetary Policy Committee (MPC), to which in 1997 the Chancellor handed the power to set interest rates. EST, BCSD-UK, and the Institute of Mechanical Engineers explicitly likened the proposed Committee to the MPC. Climate Change Capital argued that:

There are some parallels there because at the moment the Government manage the inflation using interest rates and it has given this responsibility effectively to the MPC. [… T]he Government will say they want to move to this level in emissions over this period and you have to write a letter if our emissions exceed that over a five-year average period, or something. It is very, very similar. The Government will say that this is the kind of level of emissions reductions they want from the United Kingdom and you give us recommendations to get there.[167]

125. At the same time, CCC and others also stressed the differences between the MPC and the proposed Committee on Climate Change. Kate Hampton of CCC, for instance, stressed that: "It is not a panacea. You still have to have willingness of the ministers to accept those judgments, but it is better to have a process of independent evaluation going forward than none."[168] Meanwhile, Paul Ekins told us:

No-one is proposing and I certainly would not propose that the policy recommendations of the committee were mandatory for Government in the way that the Monetary Policy Committee recommendation on the interest rate is mandatory, it actually takes the decision; because the policies on climate change are much too far-reaching, and because it is right that there should be political accountability for them.[169]

Rather, for Professor Ekins, the great value of the Committee's policy recommendations would not be that the Government should be bound to accept them, but that if it rejected them it would formally have to explain why and publicly offer an alternative, but equally effective, approach:

if they decide that they do not want to go along with those recommendations, then they will have to propose something else and that comes back to what I said right at the start about the importance of this Bill: they will not simply be able to say "No, I don't like that" because there will be a slug of carbon which these policies are scheduled to take out from emissions and they will have to find some other way of doing that.[170]

126. We heard much discussion as to exactly what the main roles of the Committee should be, whether and what priorities it should have prescribed for it, what resources it should have, who should sit on it and how they should be chosen. Much of this discussion focused on the place in the draft Bill which spells out a list of policy considerations which the Committee would be expected to take into account in formulating its recommendations, and equally, essentially the same list of considerations, which is given by the draft Bill as illustrating the backgrounds of the Committee's membership:

127. RSPB were far from alone among environmental groups in questioning the ranking of "climate science" in the Bill's list of areas of expertise required of the Committee's members. Given, they argued, that the Committee's "main role is going to be in objective advice on science":

We are concerned that the first set of skills and experience that are being asked for relates particularly to understanding of pure economics or of impacts on fiscal issues and poverty. Those are clearly very important things but as it stands at the moment we feel there should be a better balance with those people with responsibility for and understanding of the environmental policy expertise.[171]

Additionally, RSPB and WWF called for another area of expertise to be taken into account —the wider environmental considerations of sustainable development:

It does seem slightly odd to us in terms of the criteria that the Committee has to take account of. It does not seem to represent the conventional view of the three legged stool of sustainable development. There are criteria to do with economics and social impact but nothing in terms of wider impacts on the environment.

Ruth Davis of RSPB explained further:

One very important issue for those working in the environmental sector is that alongside duties to take into account issues around economic impacts and impacts on social equity we think that the Committee should have some kind of duty to take account of sustainable development in the way that it sets its aspirations for the balance between sectors. For example, if there was a massive preponderance of reliance on the power generation sector to the exclusion of everything else, we would have to understand what the implications of that were in terms of nuclear power but also in terms of the impacts of barrage projects and of major wind. We would like to be confident that the Committee had thought about that in the way that it was deciding to establish a balance between different sectors, as it is required to think about the impacts on social causes and poverty reduction.[172]

128. Other organisations also made their own requests for further issues to be prescribed for the Committee to consider. The Energy Saving Trust called for the Committee's membership to include someone with experience in helping businesses and individuals reduce their demand for carbon-intensive goods and services.[173] BCSD-UK, meanwhile, called for the Committee to be given an explicit target to maintain sustainable economic growth.[174] In terms of who would become members of the Committee, BCSD-UK argued that these should predominantly come from business:

I would like to see the people appointed to it being, as I think we have mentioned before, from areas of expertise that can help formulate that helpful direction for government, so I think it is likely to be business, to be honest. […] I would like to see it predominantly business-led but with academic input that sits closely with the business community as distinct from pure academic. […][175]

Commenting on BCSD-UK's recommendation that the Committee be charged with a duty to promote economic growth, WWF responded:

There are plenty of other government institutions which are charged with that duty already. In terms of the government's own modelling and the impact on long term GDP growth, the figures are talking about a modest shaving off what by 2050 is a very significant growth in the nation's GDP. We are not talking about grinding the economy to a halt. We are talking about a significant investment in a lower carbon future which we need to make anyhow. Stern clearly sets out that the impacts that the UK and the world would avoid by adopting that strategy would greatly outweigh the costs of the transition to a low carbon economy. That is the classic example of somebody trying to lumber the Committee with an inappropriate duty.[176]

129. However, WWF and BCSD-UK, as well as a number of other witnesses, were all in agreement that the members of the Committee should be selected for their individual expertise, and serve in a personal capacity, rather than being the representatives of a range of stakeholder groups. BCSD-UK, for instance, clarified: "I think we are talking about the type of people who should be on the board rather than their affiliation. We are not saying that there should be a member of the CBI appointed to the Committee."[177] EST argued "it is important to make sure that all sectors are actually represented on the Committee by experts but not sector representatives."[178] RSPB said: "it would be dangerous and destructive to get into a role where you have representatives of sectors on the Committee. We would like to see representatives come forward on the basis of their individual competence and expertise."[179] Dr John Rhys was clear that Committee membership "should not be based on special interest groups, as this would weaken its independence and its credibility."[180]

130. A number of witnesses went beyond this, to discuss the process that ought to be used to select members of the Committee. EST stressed "it is important that the members of the Committee are selected on their expertise in a clear and transparent manner. The Committee has to be independent, and it will only work if it is independent and, therefore, selection should meet with the recommendations and findings of the Nolan Report." RSPB, meanwhile, told us:

We have been discussing potentially the idea of a committee such as yourselves having a role in agreeing the appointments to the Committee on Climate Change. That would seem a rational thing to do and it would be interesting at some point to discuss that further.[181]

131. We support the Government's proposal to establish an independent Committee on Climate Change. The creation of such an independent body should make a significant contribution to the quality and transparency of Government climate change policy. One particularly valuable aspect of the Committee's work would be in providing challenge to, and public reporting on, Government forecasting and policy analysis. As part of the Committee's proposed statutory role to report to Parliament on UK emissions and the progress made in reducing them each year, it should be given a duty to audit the Government's publication of emissions statistics to ensure these are transparent, differentiating between emissions reductions made in this country and those funded abroad. It should also have a duty to comment annually on the assumptions and modelling used by the Government to forecast future emissions and estimate the impact of individual policies. Furthermore, the Committee should be able to make detailed policy recommendations to Government.

132. Another major contribution which the Committee on Climate Change could make would be to help to depoliticise the consideration of policies to reduce emissions, including measures which could be potentially very contentious. (We might observe that this is the same principle which has lain behind the recommendations, made over a number of years by ourselves and our predecessor Committees, for the creation of a Green Tax Commission.) There has been much discussion of the parallels between the Committee on Climate Change and the Bank of England's Monetary Policy Committee. The latter illustrates the advantages that can be gained by devolving key responsibilities to a non-party political committee of experts. At the same time, the issues involved in climate change policy are bigger and more complex than those devolved to the MPC. We conclude that, while the Committee on Climate Change could make some detailed recommendations, the Government must still choose which policies to implement. The virtue of the Committee will be that the Government must respond to it; and if Ministers reject any of the Committee's recommendations, they will have to set out why, and propose others to deliver equivalent emissions savings.

133. These virtues, of course, depend on the Committee's enjoying—and being seen to enjoy—a very high level of both subject expertise and independence. We consider that, as the conditions for membership are set out in the draft Bill, "climate science" is not given enough prominence. We recommend that this should be spelt out as the most important area for the Committee to understand and take into account. We further recommend that the Committee be given a duty to consider the wider environmental aspects of sustainable development.

134. In order to strengthen the independence of the Committee—and public perceptions of its independence—it is essential that members be appointed for their individual expertise, and serve in a personal capacity, rather than as representatives of different stakeholder groups. The appointment process itself should be open and transparent, preferably in accordance with the recommendations of the Nolan Report. To increase transparency and perceptions of independence, and in view of the importance of their role, all new appointees to the Committee should first be required to appear before the Environmental Audit Committee, to provide assurance to Parliament as to their suitability, and to highlight their thinking on tackling climate change.

RELATIONSHIP OF THE COMMITTEE ON CLIMATE CHANGE TO THE OFFICE OF CLIMATE CHANGE

135. One major development since the Climate Change Programme Review has been the creation of the Office of Climate Change (OCC). The OCC keeps a very low profile; very little information about it has been published, and it has neither a website of its own nor any pages devoted to it on the Defra website. However, the Head of the OCC, Mr Jonathon Brearley, wrote to us in connection with this inquiry to supply us with the following information:

• The OCC was set up in Autumn 2006. Its broad role is to work across Government, providing departments with advice on analysis and policy options for them to consider;
• Its approach is similar to that of the Prime Minister's Strategy Unit: to identify specific policy problems and put together a strong cross-Government team to develop and recommend options for departments to consider. Typically, projects last between 3 and 6 months, with two to eight staff working on each;
• The OCC has a headcount allocation of 35 full time equivalent staff. Staff are recruited from Defra and are brought in on loan from other government departments and secondment from other organisations.
• Among its work so far has been:
• Development of the draft Climate Change Bill.
• Supporting Defra in analysing the UK position on Phase 3 of the EU ETS.
• A review of the departmental governance of climate change policies.
• Analytical Audit of the economic rationale for government intervention to reduce greenhouse gas emissions and what mitigation policies the UK has in place.

136. We were interested in how the OCC and the Committee on Climate Change would demarcate their roles and work together, and how each would work with the Interdepartmental Analysts Group. When we questioned the OCC on this, two things became apparent: first, that this was still very much a work in progress; and two, that the OCC's priority was to avoid an inefficient and unnecessary duplication of effort:

Our relationship with the Committee on Climate Change I think is still an ongoing question. Clearly the Committee on Climate Change will need access to a huge amount of data, and a huge amount of analysis. What we do not want to have necessarily is duplication between what Government does, what the OCC does and what the Climate Change Committee does. At the moment we are thinking essentially about which models of Climate Change Committee might allow us to do both.

We are working very closely with the IAG on that and the Committee. We are looking at a number of alternatives. One really important issue is not to duplicate existing Government analysis; and also to recognise that quite a lot of the analysis which will be needed by the Committee will have to be done by Government in any case; so the Department for Transport is always going to want to have a transport model which would be relevant to the Committee. We are looking at a number of different models ranging from one where the Government effectively acts as an intelligent customer for the Committee's advice and another where more is outsourced to the Committee and have not arrived at a conclusion on exactly the shape of this model as yet.[182]

137. In view of the evidence we had heard from EST and others, that the exclusion of fiscal policy from the main analytical work performed during the Climate Change Programme Review hampered its outcomes, we asked whether the OCC was able to analyse and combine all aspects of Government policy. The answer, however, was not entirely reassuring: "I think fiscal policies remain the ground that Treasury covers; so the OCC does not carry out any work on fiscal policies."[183] Nick Mabey suggested that the OCC would not by itself be able to join up Government policy, where this was already disjointed due to conflicting policy priorities, but that it should still be able to offer some innovative solutions:

On the political level, the Office of Climate Change really makes no difference at all. It does not help you ensure that housing policy and climate policy are joined up or [aviation] policy. […] I do not think you can organisationally solve that problem; it has to be done at Cabinet level. In terms of […] finding innovative and integrated solutions, I think the Office of Climate Change has huge potential […] I think there has been a lot of people fighting about how much restrictions to put on housing and how fast to move in that sector, […] but no one was gripping that because it fell between everybody's stools in terms of departments. That is the kind of problem where the OCC should get a break out of the impasse. That is the main thing it can do, to provide creative, integrated solutions that previously were languishing in gaps between departments.[184]

138. We conclude that the Office of Climate Change is doing valuable work, and will help to improve the quality of Government climate change policy. Its main role appears to be to provide a resource which individual Departments can access for discrete pieces of research on climate change policy. It remains to be seen, however, whether it will have the remit to design truly cross-cutting policies, or the influence to ensure that all Departments build climate change into their thinking at an early stage. The OCC's lack of responsibility for considering fiscal policies is a sign that this is not the case. Also, it cannot, by itself, ensure that Government policies are joined up, so that major policy programmes—for instance, DfT's airport expansion programme—do not run directly counter to the effort to reduce carbon emissions. This requires a joint effort of Ministerial will.

139. A further issue here concerns the resourcing that is being planned for the Committee on Climate Change, and the extent to which it will be able to use its own staff and commission its own research, as opposed to relying on the data provided by the IAG and OCC. EEF saw this as being important in guaranteeing the Committee's independence:

We would like to see the Committee on Climate Change independent. We would like to see the secretariat of the Committee being independent of government as well, so it can effectively scrutinise government policy. We think that the Committee should have access to an analytical resource, including modelling, again to be able to report back effectively to government on the issues and pressures.[185]

EST had particularly strong recommendations here:

In the Bill it talks about the committee being supported by a standing secretariat of staff on detailed analysis. […] If that staff is 20 or 30 people or analytical experts, it may well be able to do all that analysis. However, if we are talking of a fairly modest staff complement, it would be insufficient to do the task in hand. We have done it on the cheap, if I can call it that, through bringing people in for specific pieces of work and that has worked up until now. The reality is that the challenge for us is far greater and we need a professional, dedicated resource to do that kind of analysis. It does not remove the need for individual work at departmental levels but the way to coordinate it across departments needs to be professional and in a permanently staffed manner.[186]

140. The Bill's Regulatory Impact Assessment states that the Committee's full staffing budget will be £2 million, and this will result in total staff numbers of around 15 to 20. This would suggest that, as planned, the Committee would have less than the complement of analytical staff which the EST believes is essential. Professor Ekins, meanwhile, believed that those staffing numbers might be sufficient (so long as all 15-20 referred to were high quality analysts; i.e., rather than 15-20 being the entire number of staff, with the number of such analysts being perhaps 10-15), but wondered about what size of research budget the Committee would be given:

I am slightly worried that the budget would not be large enough to support the level of outside research that will be necessary to make the policy recommendations properly grounded. I am not expert in what Government spends on external research, but it would be very interesting for example to see how much it had spent on external support for the Energy White Paper process that has been going on now for a couple of years and to see whether that was in any way perceived to be adequate and would cover the range of issues that the Committee on Climate Change would be expected to cover.[187]

141. The Government is right to seek to ensure that the Committee on Climate Change, the Office of Climate Change, and relevant parts of Government share resources and do not unnecessarily duplicate each other's work. But the Committee on Climate Change must have the resources to ensure that its work is wholly independent, and does not merely have to rely on the conclusions given to it by individual Departments. This point is underlined by the way in which, in the Climate Change Programme Review, the Interdepartmental Analysts Group only supplied decision-makers with one scenario for each potential policy, thus preventing the CCPR from considering the impacts of different scales and combinations of policies. As Nick Mabey put it, "It cannot just be a passive recipient of whatever is there, or it will be, perhaps, that people can hide things from it."[188] Given the importance of the Committee it needs a high quality secretariat which is adequate to support all its work and a budget for commissioning external research.

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82   The two Houses of Parliament agreed to establish a Joint Committee on the Draft Climate Change Bill, chaired by Lord Puttnam. Back

83   Cm 6764, p 13 Back

84   Kevin Anderson and Alice Bows, "A response to the Draft Climate Change Bill's carbon reduction targets", Tyndall Centre for Climate Change Research, Tyndall Briefing Note 17, March 2007 Back

85   Q260 Back

86   Uncorrected transcript of oral evidence taken before the Environmental Audit Committee on 4 June 2007, HC (2006-07) 595-i, Q10 Back

87   Ev 120 Back

88   Uncorrected transcript of oral evidence taken before the Environmental Audit Committee on 4 June 2007, HC (2006-07) 595-i, Q4, Q6 Back

89   Q26 Back

90   Alice Bows et al, Living within a Carbon Budget, Tyndall Centre Manchester, July 2006 Back

91   Bows et al, Living within a Carbon Budget, pp 165-6 Back

92   Tyndall Centre, "A response to the Draft Climate Change Bill's carbon reduction targets", footnote 9 Back

93   HM Treasury, Stern Review on the Economics of Climate Change, October 2006, p 475. Note: Stern's target range of 450-550 parts per million in the atmosphere was for all greenhouse gases (including, e.g., methane, nitrous oxide, etc.) expressed as carbon dioxide equivalent (CO2e); Stern explained that of this total, around 400-490ppm would be CO2 alone. Back

94   Q109 Back

95   Stern Review, p 292 Back

96   Environmental Audit Committee, Fourth Report of Session 2004-05, The International Challenge of Climate Change: UK Leadership in the G8 and EU, HC 105, paras 83-6 Back

97   As Clause 3 explains, the draft Bill in practice would compel the carbon budget for the period 2018-2022 to be set at a level consistent with an average annual total in 2020 that is 26-32% down on 1990 emissions. Back

98   Draft Climate Change Bill Consultation Document, HM Government, Cm 7040, March 2007, para 5.5 Back

99   Q216 Back

100   Cm 7040, cl. 3(1)(a) Back

101   Q102 Back

102   Q159 Back

103   Q218 Back

104   Uncorrected transcript of oral evidence taken before the Environmental Audit Committee on 4 June 2007, HC (2006-07) 595-i, Q5 Back

105   Uncorrected transcript of oral evidence taken before the Environmental Audit Committee on 4 June 2007, HC (2006-07) 595-i, Q55 Back

106   Q102 Back

107  DTI,MeetingtheEnergyChallenge-AWhitePaperonEnergy,May2007,para10.12,p282 Back

108  DTI,UpdatedEnergyandCarbonEmissionsProjection,May2007,p2 Back

109   Defra, "Estimated emissions of carbon dioxide (CO2) by IPCC source category, type of fuel and end user: 1970-2005", http://www.defra.gov.uk/environment/statistics/globatmos/download/xls/gatb05.xls . Note: These figures are for CO2 only, and do not take account of any "uplift factor" to reflect other greenhouse gas emissions, nor the enhanced contributions of flying at high altitudes to global warming, for instance through the formation of contrails. Back

110   Ev 114 Back

111   Explanatory Notes to the Draft Climate Change Bill, Cm 7040, para 65 Back

112   Ev 21 Back

113   Ev 120 Back

114   Q79 Back

115   Ev 120 Back

116   Q78 Back

117   Q126, Q127 Back

118   Q130 Back

119   Ev6 Back

120   Q132 Back

121   Cm6764,p71 Back

122   Cm6764,p172 Back

123   DfT, The Future of Air Transport, Cm 6046, December 2003 Back

124   Uncorrected transcript of oral evidence taken before the Environmental Audit Committee on 4 June 2007, HC (2006-07) 595-i, Q21 Back

125   Uncorrected transcript of oral evidence taken before the Environmental Audit Committee on 4 June 2007, HC (2006-07) 595-i, Q20 Back

126   P.M.d.F. Forster, K.P. Shine and N. Stuber, "It is premature to include non-CO2 effects of aviation in emission trading schemes", Atmospheric Environment 40(6), 2006, 1117-1121  Back

127   Qq 80-83 Back

128   Q282 Dr Bows Back

129   Uncorrected transcript of oral evidence taken before the Environmental Audit Committee on 4 June 2007, HC (2006-07) 595-i, Q23 Back

130   Environmental Audit Committee, The EU Emissions Trading Scheme, paras 115-117 Back

131   Uncorrected transcript of oral evidence taken before the Environmental Audit Committee on 4 June 2007, HC (2006-07) 595-i, Q22 Back

132   Environmental Audit Committee, Reducing Carbon Emissions from Transport, para 116 Back

133   Environmental Audit Committee, Pre-Budget 2006 and the Stern Review, Figure 9, p 50 Back

134   Explanatory Notes to the Draft Climate Change Bill, Cm 7040, para 65 Back

135   Uncorrected transcript of oral evidence taken before the Environmental Audit Committee on 4 June 2007, HC (2006-07) 595-i, Q20 Back

136   Q174 Back

137   Q217 Back

138   Q149 Back

139   Ev 121 Back

140   Q150 Back

141   Q173 Back

142   Ev 48 Back

143   Q198 Back

144   Uncorrected transcript of oral evidence taken before the Environmental Audit Committee on 4 June 2007, HC (2006-07) 595-i, Q31 Back

145   Draft Climate Change Bill Consultation Document, para 5.31 Back

146   Q109 Back

147   Draft Climate Change Bill Consultation Document, para 5.16 Back

148   According to Defra and DTI, this will be made up of assessments of the impact of individual measures, as well as recent trends in emissions, collected by the Interdepartmental Analysts Group and previously only reported internally to the Climate Change Programme Board, a cross-departmental board of senior officials, on a quarterly basis. Ev 117 Back

149   Ev 121 Back

150   Q2 Back

151   Q147 Back

152   Draft Climate Change Bill - Partial Regulatory Impact Assessment, Cm 7040, March 2007, paras 5.1.40-5.1.52 Back

153   Q180 Back

154   Q228 Back

155   Q228 Back

156   Q230 Back

157   Q148 Mr Staniaszak Back

158   Draft Climate Change Bill Consultation Document, paras 5.14-5.15 Back

159   Q147 Back

160   UncorrectedtranscriptoforalevidencetakenbeforetheEnvironmentalAuditCommitteeon19June2007,HC(2006-07)740,Q53 Back

161   "Bringing Urgency into UK Climate Change Policy", BIEE Climate Change Policy Group, December 2006, p 5 Back

162   Environmental Audit Committee, Twelfth Report of Session 2005-06, Transport Emissions: Government Response to the Committee's Ninth Report of Session 2005-06 on Reducing Carbon Emissions from Transport, HC 1718, para 4 Back

163   Q178 Back

164   Environmental Audit Committee, Climate Change - the UK Programme 2006,Q209 Back

165   Q188 Back

166   Q195 Back

167   Q191-3 Back

168   Q188 Back

169   Q222 Back

170   Q222 Back

171   Q161 Back

172   Q161 Back

173   Qq 139-140 Back

174   Ev 1 Back

175   Qq 54-58 Back

176   Q166 Back

177   Q57 Back

178   Q139 Back

179   Q161 Back

180   Ev 76 Back

181   Q161 Back

182   Q87 Mr Brealey, Mr Mortimer Back

183   Q111 Back

184  Uncorrected transcript of oral evidence taken before the Environmental Audit Committeeon 19 June 2007, HC(2006-07)740,Q50 Back

185   Q2 Back

186   Q143 Back

187   Q223 Back

188  Uncorrected transcript of oral evidence taken before the Environmental Audit Committeeon 19 June 2007, HC(2006-07)740,Q55 Back

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Prepared 30 July 2007